FINAL APPLICATION FOR LICENSE OF MAJOR …leapshydro.com/wp-content/uploads/2019/06/1B.-Study-28-Fire-Study-Pl… · final application for license of major unconstructed project study

FINAL APPLICATION FOR LICENSE OF MAJOR UNCONSTRUCTED PROJECT

STUDY 28

FIRE STUDY PLAN

LAKE ELSINORE ADVANCED PUMPED STORAGE PROJECT

FEDERAL ENERGY REGULATORY COMMISSION PROJECT NUMBER 14227

Applicant:

THE NEVADA HYDRO COMPANY, INC. 2416 Cades Way

Vista, California 92081 (760) 599-1813

(760) 599-1815 FAX

June 2019

FINAL FIRE STUDY PLAN

LAKE ELSINORE ADVANCED PUMPING STORAGE PROJECT (PROJECT NUMBER 14227-003)

RIVERSIDE COUNTY, CALIFORNIA

Submitted to: Mr. David Kates

The Nevada Hydro Company 3510 Unocal Place, Suite 200

Santa Rosa, CA 95403

Prepared by: Wood Environment & Infrastructure Solutions, Inc.

3120 Chicago Avenue, Suite 110 Riverside, California 92507

Tel: (951) 369-8060

June 5, 2019

Wood Project No.: 1855400727

LEAPS Final Fire Study Plan June 5, 2019

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TABLE OF CONTENTS Page

ACRONYMS AND ABBREVIATIONS .......................................................................................... iii 1.0 INTRODUCTION ............................................................................................................... 1 2.0 BACKGROUND ................................................................................................................ 1 3.0 METHODOLOGY .............................................................................................................. 2 4.0 PHYSICAL SETTING ........................................................................................................ 4

4.1 Location ................................................................................................................. 4 4.2 Regional Land Use ................................................................................................ 4 4.3 Climate .................................................................................................................. 4 4.4 Topography ........................................................................................................... 5 4.5 Existing Regional Infrastructure ............................................................................ 6

5.0 BIOLOGICAL SETTING .................................................................................................... 6 5.1 Ecological Setting .................................................................................................. 6 5.2 Vegetation ............................................................................................................. 6 5.3 Fuels and Fuel Moisture ........................................................................................ 7

6.0 FIRE STUDY ELEMENTS ................................................................................................ 7 6.1 Fire History ............................................................................................................ 7 6.2 Fire Season ........................................................................................................... 8 6.3 Wildfire Danger ...................................................................................................... 8 6.4 Wildfire Preparedness and Response ................................................................. 10

6.4.1 Fire Plans ................................................................................................ 11 6.4.2 Staffing .................................................................................................... 11 6.4.3 Aviation .................................................................................................... 11 6.4.4 Safety Measures ...................................................................................... 11

7.0 RESULTS & DISCUSSION ............................................................................................. 11 7.1 Transmission Line Alternatives............................................................................ 11 7.2 Hazardous Fuel Loading ..................................................................................... 12 7.3 Infrastructure Effects ........................................................................................... 12

7.3.1 Fire Management Operations .................................................................. 12 7.3.1.1 Ground Operations .............................................................................................. 12 7.3.1.2 Aerial Operations ................................................................................................. 12 7.3.1.3 Water Sources ..................................................................................................... 13

7.3.2 Wildfire Risk ............................................................................................. 13 8.0 RECOMMENDATIONS ................................................................................................... 13 9.0 REFERENCES ................................................................................................................ 13

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ACRONYMS AND ABBREVIATIONS

BLM Bureau of Land Management

CDFW California Department of Fish and Wildlife

CNF Cleveland National Forest

CWHR California Wildlife Habitat Relationship System

EIS Environmental Impact Statement

FEIS Fire Effects Information System

FERC Federal Energy and Regulatory Commission

FLA Final License Application

FRAP Fire and Resource Assessment Program

kV kilovolt

LEAPS Lake Elsinore Advanced Pumping Storage

MOU Memorandum of Understanding

MTBS Monitoring Trends Burn Severity

NCEP National Centers for Environmental Prediction

NDFD National Digital Forecast Database

NERC North American Electric Reliability Cooperation

Nevada Hydro The Nevada Hydro Company

NFFL National Forest Fire Laboratory

NOAA National Oceanic and Atmospheric Administration

NOI Notice of Intent

NVC National Vegetation Classification

NWS National Weather Service

ROD Record of Decision

RRU Riverside Unit

RWQCB Regional Water Quality Control Board

USEPA U.S. Environmental Protection Agency

USFS U.S. Forest Service

USFWS U.S. Fish and Wildlife Service

USGS U.S. Geological Survey

WFAS Wildland Fire Assessment System

WUI Wildland Urban Interface


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1.0 INTRODUCTION

The Lake Elsinore Advanced Pumped Storage (LEAPS) Project (Project No. 14227) is located in an area that has historically been impacted by wildfires, where wind patterns can potentially exacerbate wildfires, and where recent residential development has occurred along the border of the Cleveland National Forest (CNF). These conditions, as further exemplified by the Holy Fire which occurred in Fall 2018, indicate that there may be a greater fire risk associated with the staff alternative than was originally analyzed in the 2007 Final Environmental Impact Statement (EIS). As a result, a Fire Study was requested by the U.S. Forest Service (USFS) and Decker Landowners to assess the potential impacts of the LEAPS Project on regional fire management operations. This Fire Study Plan has been prepared for the USFS and the Federal Energy Regulatory Commission (FERC) to initiate the completion of a Fire Study (Study 28) originally requested by FERC in a comment letter dated June 15, 2018 (FERC 2018).

The overall objective of this Fire Study Plan is to describe the methodologies and metrics proposed to assess the potential fire risk associated with the proposed LEAPS Project. The Fire Study Plan outlines the general approaches to characterizing: biological and physical conditions of the region; fire history and conditions that contribute to wildfire danger; and regional wildfire fighting operations and preparedness. Following approval of the Final Fire Study Plan by USFS and FERC, these approaches will be implemented to perform an analysis of the potential impacts and increased fire risk associated with the LEAPS Project

2.0 BACKGROUND

In 2004, the Elsinore Valley Municipal Water District and Nevada Hydro filed an application for an original license with FERC for the construction and operation of the LEAPS Project located in Riverside County, San Diego County, and Orange County. The LEAPS Project is an energy generation and storage project. As originally proposed, the it would occupy approximately 2,412 acres of Federal lands and would include a lined upper reservoir with a dam and dike, an underground powerhouse, and a 32-mile, 500-kilovolt (kV) transmission line linking two existing transmission lines to the north and south of the Project area. A staff alternative – consisting of modifications to the original design as requested by the USFS and FERC – was also considered in the 2007 Final EIS. The staff alternative included an alternate location for the upper reservoir, which would provide the same usable storage with a smaller total footprint, as well as an alternate alignment for the transmission line to avoid crossing private inholdings in the CNF, thereby avoiding potential conflicts with fire suppression activities. FERC granted the proposed LEAPS Project a preliminary permit to study the staff alternative on October 24, 2012.

On June 1, 2017, Nevada Hydro filed a Notice of Intent (NOI) to file a license application and a draft license application for the LEAPS Project (Project No. 14227), which had been substantially re-designed to be similar to the staff alternative that was assessed in the 2007 Final EIS. In its NOI, Nevada Hydro requested that FERC’s pre-filing licensing requirements (i.e., pre-filing scoping, comments and information, or study requests, the preparation of and comments on a proposed study plan, resolution of disputes over studies, and notice of the Applicant’s intent to file a draft license application) be waived to allow it to proceed directly to filing a Final License


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Application (FLA). FERC staff approved Nevada Hydro’s waiver request in September 2017, noting that stakeholders could comment on the adequacy of the FLA during FERC’s post-filing procedures.

The project presented in the FLA proposes similar facilities and alignments as the staff alternative for Project No. 11858 considered by FERC in the 2007 Final EIS, with a few distinctions. Nevada Hydro is now proposing to develop two separate primary transmission lines. The proposed alignment of the transmission lines is substantially similar to the alignment reviewed in the 2007 Final EIS; however, FERC has also requested analysis of three alternate alignments for the northern portion of the transmission line are being considered by Nevada Hydro. Additionally, the Case Springs substation has been sited in the CNF, rather than Camp Pendleton. This new substation location was chosen in consultation with USFS after the Record of Decision (ROD) for the 2007 Final EIS for Project No. 11858 was issued.

After Nevada Hydro filed a FLA in October 2017, study requests were filed by Federal and state agencies, Native American tribes, and non-governmental organizations, including USFS, U.S. Fish and Wildlife Service (USFWS), California Department of Fish and Wildlife (CDFW), Santa Ana Regional Water Quality Control Board (RWQCB), Temecula Band of the Luiseño Mission Indians, the Decker Canyon Property Owners, EHOF II Lakeside, LLC, the City of Lake Elsinore, and the Center of Biological Diversity (with San Bernardino Valley Audubon Society, Endangered Habitats League, Audubon California, and Sierra Club). Among the numerous study requests, FERC, in a letter on June 15, 2018, requested that Nevada Hydro complete a Fire Study (Study 28).

3.0 METHODOLOGY

Our proposed approach for obtaining the information required to perform the analyses are outlined in this section, as requested in the June 15, 2018 letter from FERC.

Publicly accessible Federal, state, and interagency sources will be used to gather data in an effort to summarize the physical (e.g., location, population, climate, etc.) and biological (e.g., vegetation, wildfire history, etc.) characteristics of the region immediately surrounding the Project area. Additionally, the USFS will be contacted to gather data regarding response times, available equipment, water sources, etc. (Data and communications from any other local agencies [e.g., CAL FIRE] will also be incorporated, provided that CNF staff is able to facilitate communication and data sharing.) Methods for specific characteristics discussed below in Physical Setting, Biological Setting, and Fire Study Elements, are described in more detail under each heading. Below the discussion of each topic is a bulleted list of agencies or sources of data to be utilized. Sources used are provided in the bibliography or are indicated in the text as a URL.


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Figure 1. Location of the Lake Elsinore Advanced Pump Storage (LEAPS) Project in Riverside County, San Diego County, and Orange County, California.


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4.0 PHYSICAL SETTING

4.1 Location

The LEAPS Project is located within an approximately 2,412-acre site located in Riverside County, San Diego County, and Orange County. The Project site is located in and near the CNF, a 460,000-acre parcel of USFS-managed public land situated in San Diego, Orange, and Riverside counties in Southern California. CNF is a highly dynamic environment, with rapid residential growth nearby, varied topography, and a Mediterranean climate typical of the region.

The residential growth nearby includes several communities and developments. Communities on the east-facing side of the CNF and the Project area include Lake Elsinore, El Cariso (located southwest of Lake Elsinore and west of Ortega Highway), and Lakeland Village (located south of Lake Elsinore and east of Ortega Highway). On the western portion of the Project area, a small residential community, Rancho Capistrano, is located on a private in-holding in the CNF. Therefore, this area has a high proportion of what is known as the wildland urban interface (WUI)

4.2 Regional Land Use

Federal, state, and county population data and land use plans will be referenced to accurately describe economic developments, population trends, management plans, and current land use of the area surrounding the LEAPS Project site. Relevant land use and demographics data that will be assessed in the Fire Study includes, but is not limited to, the following:

USFS

U.S. Census Bureau

o U.S. Census Bureau Population Estimates

Riverside County

o Riverside County Center for Demographics Census Reports

o Riverside County General Land Use Plan

o Riverside County Economic Development Agency Annual Reports

o Riverside County High Opportunity Area Maps

o Existing Vegetation: Region 5 South Coast (CalVeg)

o CNF Land Management Plan, Goal 1.1

4.3 Climate

National Oceanic and Atmospheric Administration (NOAA) 1981-2010 Climate Normals (see Table 1) will be used describe the existing climate at the Project site (NOAA 2018). This data will provide an overall context for other fire risk factors that will be evaluated in the Fire Study. Further, existing Nature Conservancy climate models (e.g., ClimateWizard) will be used to compare long-term average climate data between 1961-1990 to long-term modeled climate data in 2040-2069, and to assess long-term climate conditions as they relate to file risk.


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TABLE 1. 1981-2010 TEMPERATURE NORMALS AT LAKE ELSINORE, CA (USC00042805)

MONTH

PRECIP (IN) AVG LOW TMP

(°F) AVG TMP (°F)

AVG HIGH

TMP (°F)

January 3.04 39.3 52.6 65.9

February 2.91 40.9 54.2 67.5

March 1.77 43.4 57.9 72.3

April 0.62 46.8 62.0 77.3

May 0.14 52.4 68.1 83.9

June 0.02 56.6 73.8 91.1

July 0.21 61.9 79.8 97.7

August 0.01 62.7 80.8 98.9

September 0.24 59.1 76.4 93.6

October 0.61 52.3 67.8 83.3

November 0.86 43.5 58.4 73.3

December 2.01 38.2 51.8 65.3

Source: NOAA 2019.

Notes: The Lake Elsinore National Climatic Data Center (NCDC) Station (USC00042805) Relevant climate data that will be assessed in the Fire Study includes, but is not limited to, the following:

NOAA

o 1981-2010 Climate Normals (Elsinore Station, El Toro Station)

The Nature Conservancy

o Climate Wizard

4.4 Topography

Topography influences the movement of air, directing a wildfire’s course. Slope is a key topographic feature in fire behavior. The topography of the area in and around the LEAPs Project site is highly varied and consists of mountainous regions, large valleys, and high elevation plateaus. Useful sources of topographical data (e.g. U.S. Geological Survey [USGS] topographic maps, geotechnical studies, etc.) will be reviewed to identify areas – in particular, those beneath the proposed transmission line and alternative transmission line routes – that are at risk for extreme fire behavior (e.g., canyons, ravines, etc.). Relevant topographical data that will be assessed in the Fire Study includes, but is not limited to, the following:

USGS Topographic Maps (USGS 1997a, 1997b, 1997c)

Available geotechnical studies prepared for the LEAPS Project


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4.5 Existing Infrastructure

As stated previously, the area around the LEAPS Project site and the CNF has developed rapidly, and infrastructure associated with electrical systems is already present in the region. A desktop review of the area in and around the LEAPS Project site will be conducted to quantify the amount and types of electrical infrastructure already in place, roads, and trails utilized for fire management operations, and with any relevant information. Data that will be assessed in the Fire Study includes, but is not limited to the following:

California Energy Commission Electric Transmission Line Geographic Information Systems (GIS) Datasets

5.0 BIOLOGICAL SETTING

5.1 Ecological Setting

Readily available ecoregion data from the U.S. Environmental Protection Agency (USEPA) and other agencies will be utilized to better understand and describe the ecosystems surrounding the LEAPS Project site. Ecoregions denote areas of general similarity in ecosystems and in the type, quality, and quantity of environmental resources; they are designed to serve as a spatial framework for the research, assessment, management, and monitoring of ecosystems and ecosystem components. USEPA Level IV Ecoregion details will be described for the area around the LEAPS Project site. Level IV is a further subdivision of level III ecoregions (USEPA 1997). Relevant ecological data that will be assessed in the Fire Study includes, but is not limited to the following:

CalVeg Ecoregions

EPA Level IV Ecoregion Data

5.2 Vegetation

The National Vegetation Classification (NVC) system will be used to characterize the NVC communities (classified at the Group level) dominant in the area surrounding the LEAPS Project site. Region 5 of the USFS encompasses the entire State of California and provides a variety of publicly-available spatial data pertaining to existing vegetation communities and fuels for the South Coast (USFS 2018a). This data is provided via the USFS Geodata Clearinghouse (USFS 2018b). In addition, the California Wildlife Habitat Relationship System (CWHR) provides information on the structure, composition, and natural succession of vegetation communities in the State of California. Lastly, the USFS Fire Effects Information System (FEIS) provides fire regime information for vegetation communities throughout California. These sources will be used the characterize the vegetation types in the region. Relevant vegetation data that will be assessed in the Fire Study includes, but is not limited to the following:

USFS

o NVC Communities: Region 5 South Coast (CalVeg)


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o Ecological Sections: Potential Natural Vegetation

o CWHR Vegetation Community Data

o USFS FEIS Vegetation Community Data

A desktop review of vegetation mapping (e.g., NVC communities) data will be combined with any on-site vegetation mapping and descriptions from local fire personnel to form an accurate description of vegetation communities surrounding the LEAPS Project site. On-site vegetation mapping is to be conducted at the Project site under separate studies requested by FERC.

5.3 Fuels and Fuel Moisture

A discussion of fuel types (i.e., 1-hour fuels, 10-hour fuels, 100-hour fuels, and 1,000-hour fuels) and the Northern Forest Fire Laboratory (NFFL) 13 Standard Fuel Models for the Project area will be included. In addition to data from the USFS Geodata Clearinghouse, CAL FIRE’s Fire and Resource Assessment Program (FRAP) provides a variety of publicly-available fuels and fire hazard maps GIS data for the state (CAL FIRE 2012). Relevant fuels and fuel moisture data that will be assessed in the Fire Study includes, but is not limited to, the following:

USFS

o Western Bark Beetle Strategy Data

o Hazardous Fuels Treatment Reduction Areas

o National Fuels Moisture Database

CAL FIRE FRAP Mapping

o Surface Fuels

o Fuel Rank

o Fire Threat

o Tree Mortality Mapper

A desktop review of surface fuels data, fuels reduction projects, and tree mortality data will be combined with available fuels models and descriptions from local fire personnel to form an accurate description of existing fuel types and fuel loads surrounding the LEAPS Project site.

6.0 FIRE STUDY ELEMENTS

6.1 Fire History

The LEAPS Project is located in an area that has historically been impacted by frequent and intense wildfires. Due to a host of variables (e.g., vegetation changes, climactic factors, constructed barriers) wildfires rarely burn uniformly over large areas. As a result, when viewed at the landscape level ,fire history can often look like a patchwork or mosaic of past fire activity. Publicly-available mapping data will be used to accurately depict and describe the fire history of area surrounding the LEAPS project. Ignition sources (e.g., transmission lines, unattended campfires, WUI) will also be examined. Relevant fire history data that will be assessed in the Fire Study includes, but is not limited to, the following:


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USFS

o Spatial Wildfire Occurrence Data for U.S. 1992-2015

o Monitoring Trends Burn Severity (MTBS) Burn Area Boundaries

CAL Fire FRAP Mapping

o Fire Perimeters Database

National Wildland Fire Coordination Group

o Holy Fire Incident Information

o Holy Fire Perimeter Map

6.2 Fire Season

Regional wildfire danger statistics will be derived from the Wildland Fire Assessment System (WFAS) – originally developed by the Fire Behavior unit at the Fire Sciences Laboratory in Missoula, Montana – to define the historical fire season start and end dates, as well as the historic causes of wildfire ignition. The WFAS also provides access to the National Fuels Moisture Database (USFS 2018c), which provides publicly available historical fuel moisture data from a vast network of sampling locations across the country. Additionally, CAL FIRE has a log of historical wildfire activity statistics for the entire state, Redbooks, for each year dating back to 1943 (CAL FIRE 2018). Through the National Fuels Moisture Database, graphs and tables of the fuel moisture for the LEAPS Project area can be viewed on a bimonthly basis and compared across years to develop an accurate summary of historical and projected future fuel moisture fluctuations. Relevant fire season data that will be assessed in the Fire Study includes, but is not limited to the following:

USFS

o WFAS

o National Fuel Moisture Database

o Data from CNF, as available

CAL Fire

o Historical Wildfire Activity Statistics (Redbooks)

6.3 Wildfire Danger

Readily accessible Federal, state, and interagency sources will be evaluated in order to characterize wildfire danger in the region of the LEAPS Project. In addition, information available from past fires in the region – including the Holy Fire – will be reviewed for the conditions present at the time of these conflagrations.

As the foundation of the National Weather Service (NWS) Digital Services Program, the National Digital Forecast Database (NDFD) consists of gridded forecasts of sensible weather elements (e.g., maximum temperature, cloud cover, wind speed, relative humidity, etc.), which can be used to make a determination regarding the level of wildfire danger (i.e., “low”, “moderate”, “high”, “very


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high”, and “extreme”). The NDFD contains a matrix of digital forecasts as reported by NWS field offices working in collaboration with the National Centers for Environmental Prediction (NCEP).

Since 2007, WFAS has been producing wildfire danger forecasts using data from the National Digital Forecast Database (USFS 2018c). However, overall wildfire danger throughout a region is extremely localized given the varying microclimates, fuels, and topographies that occur over large land areas. Additionally, while the WFAS maintains data on observed wildfire danger across the country, uniform reporting has not yet been achieved. Although some stations report data regularly, other stations report more sporadically, therefore it is not possible to compare wildfire danger ratings at one station or within one particularly region over large expanses of time.

In order to give the most accurate representation of wildfire danger severity, the WFAS will be reviewed for the reporting stations located closest to the LEAPS Project site (e.g., El Cariso Fire Station). Data from station(s) near the LEAPS Project site will then be compiled and analyzed to give an effective summary of wildfire danger levels for the area on an annual and monthly basis. In addition, this data will also be compared with wildfire activity statistics, provided in the Redbooks, on a regional, county, and monthly basis in order to provide a summary of the wildfire history for the area surrounding the LEAPS Project site.

In addition to WFAS, CAL FIRE has information available on multiple variables of wildfires in California, providing an overview of wildfire danger characteristics for the state as a whole. CAL FIRE’s existing mapping of fire hazard severity zones, and fire threat for the State of California will be taken into consideration when developing summary of wildfire danger levels in the area. CAL FIRE defines fire threat as a combination of two factors: 1) fire frequency, or the likelihood of a given area burning; and 2) potential fire behavior (i.e., hazard). These two factors are combined to create threat classes ranging from low to extreme. Fire threat will be used to estimate the potential for impacts on various assets and values susceptible to fire. Impacts are more likely to occur and/or be of increased severity for the higher threat classes (CAL FIRE 2012).

CAL FIRE data and information will also be used to characterize wildfire danger originating from electrical infrastructure.

Relevant fire season data that will be assessed in the Fire Study includes, but is not limited to the following:

USFS

o Spatial Wildfire Occurrence Data for U.S. 1992-2015

o MTBS Burn Area Boundaries

o WFAS wildfire danger adjective class ratings

CAL FIRE FRAP Mapping

o Fire Hazard Severity Zones

o Fire Threat

o California Fire Hazard Reduction Projects


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6.4 Wildfire Preparedness and Response

The LEAPS Project area and agencies are responsible for fire protection in the region will be summarized in this section. Wildfire fighting in Riverside County is undertaken by the USFS, CAL FIRE, and various local agencies including the Riverside County Fire Department. Many interagency fire groups exist in Southern California and the surrounding regions, necessitated by the high cost and technical skill required of fighting wildfires. The level of resources and personnel and equipment available at any given time fluctuates depending on the time of year, location, and wildfire danger. In addition to this, residential development near the proposed LEAPS Project complicates the properties and structures that need to be protected. The CNF, in conjunction with CAL FIRE, Bureau of Land Management (BLM), and numerous other state, county, and local control organizations, maintain a constant state of readiness in an effort to keep fire-related damage to a minimum.

The Fire Study will describe how the LEAPS Project would affect an/or support wildfire suppression efforts, serving as a basis for the preparation of a Memorandum of Understanding (MOU) to formalize responsibilities and procedures during a wildfire, including the potential availability of upper reservoir water for firefighting. Relevant data that will be assessed in the Fire Study includes, but is not limited to, the following:

USFS

o Existing fire plans and procedures

o Completed hazardous fuels reduction projects

o Firefighter safety rules/procedures (e.g., general and related to infrastructure/power lines)

o Existing safety protocols and avoidance requirements for aircraft working near powerlines

o Direct Communications and data received from CNF

o Land, fuel, or fire management operation limitations due to infrastructure concerns

o Impacts on fuel breaks or fuels reduction project effectiveness

CAL FIRE

o Riverside Unit (RRU) Fire Danger Operating Plan

o Riverside Unit Strategic Fire Pan

o Direct Protection Area Mapping

o California Fire Hazard Reduction Projects

Local Communities (e.g., El Cariso and Lakeland Village)

o WUI documents and information

o Wildfire preparedness documents

o Local fire plans, fire drills, public training, fire detection systems, hazardous fuels reduction projects, control methods, and evacuation/escape procedures


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The Fire Study will examine wildfire preparedness and response times in the Project area as outlined below.

6.4.1 Fire Plans

Existing wildfire plans (e.g., CNF Fire Plan[s], RRU Firing Danger Operating Plan, Riverside Unit Strategic Fire Plan), and associated control methods, will be identified and described in this section. Potential conflicts and/or required revisions to these plans will be thoroughly discussed.

6.4.2 Staffing

Firefighting staffing levels and assets, including peak staffing periods, for Federal, state, and interagency organizations will be summarized. Information from CNF – and other state and local agencies – will be necessary to accurate describe staffing.

6.4.3 Aviation

Aircraft are used extensively in wildland fire suppression efforts in California. Current aircraft inventory, use, and concerns associated with potential impacts to fire suppression efforts (e.g., impacts to aircraft) will be described in this section. Information from CNF – and other state and local agencies – will be necessary to accurately describe these assets and activities.

6.4.4 Safety Measures

Large fires are an inevitable part of Southern California ecosystems, with flammable vegetation, extreme fire weather, and steep topography being key factors in the area near the proposed Project Area. Ignition in these ecosystems is commonly caused by people, and residential areas around the proposed Project Area have pushed up into the foothills in many places. This has led to a large increase in the amount of WUI areas that are at risk and in need of protection from wildland fire. Existing fire safety measures in the LEAPS Project area (e.g., CNF Fire Plan[s], CAL FIRE Fire Plan[s], fire drills, public awareness training, fire detection systems) are needed to populate this section. In addition, any regional evacuation/escape procedures available from agencies would assist in characterizing safety measures. 7.0 DISCUSSION

Empirical data and anecdotal evidence obtained during this Fire Study will be presented in this section. Section 7 will also contain a discussion of objectives, investigation findings. Documentation of data will be summarized in tables and on figures, as appropriate.

7.1 Transmission Line Alternatives

A discussion of the alternative alignments for the LEAPS Project and their potential fire risks will be included in this section. This analysis will rely heavily on descriptions of the existing physical and biological features, including vegetation and fuels, described in Section 4 and Section 5. The


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risks associated with the transmission line configurations and their potential to ignite wildfire due to high winds or other impacts will be emphasized. Additional discussion will be provided regarding potential impact on wildfire preparedness and response using the metrics described in Section 6.4.

7.2 Hazardous Fuel Loading

An accurate description of existing fuel types and fuel loads surrounding the LEAPS Project site will be combined with a spatial analysis to assess the extent to which the infrastructure associated with the LEAPS Project will impact hazardous fuels, and the potential for these fuels to produce extreme fire behavior. This analysis will provide a thorough discussion of required vegetation buffers from the transmission lines. In addition, the Fire Study will discuss the effectiveness of existing and proposed fuel breaks and existing or proposed fuels reduction projects located within these areas.

7.3 Infrastructure Effects

7.3.1 Fire Management Operations

The construction of the proposed LEAPS Project, particularly the 32-mile, 500-kV transmission line, could result in potential impacts to fire suppression efforts. At the very least, the additional infrastructure would increase the number of structures and resources that would need to be protected in the event of a wildfire, which may divert firefighting resources away from perimeter control. The Fire Study will utilize information and metrics described in Section 6.4 – including existing procedures, safety protocols (especially protocols for personnel and equipment near electric infrastructure), studies, and other anecdotal information – to describe the potential effects proposed infrastructure associated with the LEAPS Project could have on fire management operations.

7.3.2 Ground Operations

Impacts to access from roads, trails, and other travel paths for firefighting from the LEAPS Project will be thoroughly discussed. This will include a thorough description of the approximately 5.2 miles of permanent access roads will be constructed to aid in access to towers substations and other various pieces of the infrastructure. Each of the proposed utility corridors would be assessed – in terms of length, existing topography, existing vegetation and fuels etc. – to determine potential impacts associated with powerline avoidance requirements for personnel safety and indirect effects on incident response times, travel times, etc.

7.3.3 Aerial Operations

Impacts to aircraft providing firefighting support will be discussed and will include an assessment of avoidance requirements for proposed towers and power lines. Each of the proposed utility corridors would be assessed to determine potential impacts associated with powerline avoidance requirements for personnel safety.


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7.3.4 Water Sources

The updated design for the upper reservoir (refer to Figure 1) that is analyzed in the 2007 EIS remains lined and within the CNF as in previous designs, but it now has a smaller and deeper footprint while retaining the original storage capacity. It is proposed to be located in Decker Canyon, in CNF. In addition to the benefit of having the reservoir closer to Lake Elsinore, the upper reservoir’s presence in CNF could provide a source of water to fight wildfires within the CNF. The Fire Study will utilize any available fire management protocols, studies on water sources suitable for firefighting, and direct communications with the CNF to discuss and analyze the proposed upper reservoir’s potential use as a water source for fire management operations.

7.4 Wildfire Risk

Wildfires can start at transmission lines or substations for a variety of reasons. The Fire Study will identify previous regional studies on the fire risk of 500-kv transmission lines to describe the potential for project transmission lines to ignite wildfires. The Fire Study will also identify mandated fire risk reduction measures (e.g., vegetation management, powerline fire patrol, etc.) undertaken by similar facilities and describe how these measures can mitigate potential risk. Relevant data that will be assessed in the Fire Study includes, but is not limited to the following:

Historical Wildfire Activity Statistics (Redbooks)

North American Electric Reliability Corporation (NERC) Vegetation Management Standards

California Fire Prevention Standards for Electrical Utilities

Deenergizing technology for fire prevention

Potential indirect impacts associated with service interruptions during a wildfire

8.0 RECOMMENDATIONS

Recommended actions based on the results of analysis above will be made with reference to maximizing safety and minimizing wildfire risk for the LEAPS Project.

9.0 REFERENCES

CAL FIRE. 2018. Wildland Fire Activity Statistics (Redbooks). Available at: http://www.fire.ca.gov/fire_protection/fire_protection_fire_info_redbooks.

CAL FIRE. 2012. Fire and Resource Assessment Program. Available at: http://frap.fire.ca.gov/

National Oceanic and Atmospheric Administration (NOAA). 2018. Data Tools: 1981-2010 Normals. Available at: https://www.ncdc.noaa.gov/cdo-web/datatools/normals.

NOAA. 2019. Climate data and reports | National Oceanic and Atmospheric Administration. Available from https://www.noaa.gov/climate-data-and-reports [accessed 18 January 2019].


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U.S. Environmental Protection Agency (USEPA). 1997. Level III ecoregions of the continental United States (revision of Omernik, 1987): Corvallis, Oregon, U.S. Environmental Protection Agency - National Health and Environmental Effects Research Laboratory Map M-1, various scales

U.S. Forest Service (USFS). 2018a. Region 5 Vegetation Classification Mapping. Available at: https://www.fs.usda.gov/detail/r5/landmanagement/resourcemanagement/?cid=stelprdb5347192.

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